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BOI Filing Requirement: ON HOLD

I’ve posted several warnings in the past year about the Beneficial Ownership Information (BOI) filing deadline of December 31, 2024. The requirement comes from the Corporate Transparency Act, and requires businesses to file information about who owns the business in order to aid law enforcement.

That deadline is now ON HOLD as a Federal Court in Texas has issued a preliminary injunction against the entire Corporate Transparency Act, effectively suspending the BOI filing deadline. This means that for now you do not have to file BOI.

The case is Texas Top Cop Shop, Inc., et al. v. Garland, et al., Case No. 4:24-cv-478 (E.D. Tex.). It is likely that there will be further developments from this case, as this is only a preliminary injunction. The preliminary injunction order was a whopping 79 pages long, so it is a great read for anyone looking to understand the court’s reasoning.

This is not the first case to say that the requirement is unconstitutional: National Small Business United v. Yellen, No. 5:22-cv-01448 (N.D. Ala.) did so earlier this year; but it is the first to issue a nationwide injunction blocking enforcement of the filing requirement.

Past MARPA Blog Posts on this Subject:

About Jason Dickstein

Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. Since 1992, he has represented aviation trade associations and businesses that include aircraft and aircraft parts manufacturers, distributors, and repair stations, as well as both commercial and private operators. Blog content published by Mr. Dickstein is not legal advice; and may not reflect all possible fact patterns. Readers should exercise care when applying information from blog articles to their own fact patterns.

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